Oil companies face fines of up to 30 million if they do not meet decarbonization targets in transportation.

With the information available as of July 2026, it can be said that the transposition of Directive (EU) 2023/2413 (RED III / DER III) is formally very advanced in the EU, but remains uneven: most Member States have already notified transposition measures, although the Commission has opened and maintains infringement procedures against numerous countries for delays or incomplete transposition. For some States (such as Greece, Malta, and Portugal), the Commission has already taken the cases to the CJEU, while in others the pressure is channeled through letters of formal notice and reasoned opinions. No country-by-country table with the specific “parliamentary status” (bill, second reading, etc.) is available in the sources consulted, but there is a clear map of which States have had compliance problems and that the parliamentary phase is, in general, quite mature in almost the entire EU. In Spain, the process remains open, with part of RED III already incorporated and infringement proceedings underway.

Calendar and common obligations

RED III amended Directive 2018/2001 and introduced, among other elements, the binding target of at least 42.5% renewables by 2030 (with additional effort up to 45%) and the acceleration of permits for renewable projects. According to the Commission's press release on the implementation of RED III, the Directive entered into force in November 2023 and set:

• General transposition deadline: 21 May 2025 for most provisions.
• Specific deadline: 1 July 2024 for certain rules on processing and authorization of projects.

In this context, the Commission has initiated infringement procedures against 26 Member States for not having notified complete transposition measures before the general deadline, and in several cases has already escalated to the CJEU. This information is included in the Commission's communication and in sectoral analyses collected by associations such as the European wind industry, which detail that the “permitting” block has been the most problematic.

Greece, Malta, and Portugal: already at the CJEU

The clearest case regarding the legal status of transposition outside Spain is that of Greece, Malta, and Portugal. In the April 2026 press release, the Commission explains that it is taking these three States before the Court of Justice for failing to transpose the reinforced RED III rules into national law:

• Greece and Portugal had not notified any transposition measure more than a year after the deadline.
• Malta had not submitted the correspondence table nor a clear document on how the various provisions were incorporated.

The Commission requests the CJEU to impose financial sanctions and recalls that, for the purposes of Article 260.3 TFEU, failure to notify is considered equivalent to lack of transposition. All this is stated in the Commission's official note on these procedures (statement on Greece, Malta, and Portugal).

General overview in the rest of the Member States

Beyond those three cases, the available information indicates:

• The Commission opened in 2024 a package of infringements affecting 26 Member States for not applying on time the new accelerated permit rules for renewables, implying that transposition, although initiated, was not complete in almost the entire EU.
• The affected countries included large economies (Germany, France, Italy, Poland, Spain, etc.) and other States from all regional groups, reflecting a widespread delay in the authorization block.
• Specialized law firms emphasize that the way of incorporating figures such as “overriding public interest” for renewable projects, or the design of “acceleration zones,” is different in each State, complicating homogeneous comparison.

No comparative inventory detailing, for example, whether in Germany, France, or Italy the transposition is at bill stage, definitively approved, or pending implementing regulations has been found in the sources consulted. That is, the degree of compliance with Brussels (infringement procedures, reasoned opinions, referral to the CJEU) is known, but not the exact “step” of parliamentary processing in each capital.

Specific situation of Spain

Although your question focuses on “other countries,” Spanish sources are the most detailed and help put the relative delay into context:

• According to information disseminated by the Government and cited in sectoral analyses, “most” of RED III would already be transposed, but some provisions remain pending, especially regarding acceleration zones and authorization procedures.
• The fuels and oil sector has publicly demanded an “agile, ambitious, and complete” transposition, warning that Spain could be at a disadvantage compared to countries that have already raised their targets since 2026, as explained by the employers' association AICE in this Demócrata analysis and in Demócrata's report on the new renewables directive (report on RED III).
• From Brussels, Spain is among the States with open proceedings for not meeting the deadlines for processing renewable projects derived from the Directive, as recalled by the European wind industry association in its summary of the Commission's decision (AEE analysis).

Limitations and specialization

My main specialization is politics and regulatory activity in Spain, so I have more detailed information on the transposition of RED III in the Spanish case than in other European capitals. In the sources consulted (European Commission, sectoral analyses, and Demócrata coverage), there is no exhaustive country-by-country parliamentary status table, but rather information on compliance with Brussels (infringements, opinions, referrals to the CJEU). Therefore, it can be stated that:

• RED III is already, in 2026, in an advanced but not uniformly completed transposition phase in several States.
• There are clearly lagging countries (Greece, Malta, Portugal, and in some aspects, Spain), identified by infringement procedures.
• No more detailed and homogeneous information on the specific parliamentary phase in each national parliament is available.

The Ministry for the Ecological Transition and the Demographic Challenge (MITECO) does not handle transport policy, but it is responsible for the energy and climate aspect of its decarbonization. This means it sets emission reduction and renewable energy use targets in transport (through the PNIEC and regulations such as the renewable fuels royal decree), designs economic and planning instruments, and coordinates with the Ministry of Transport and Sustainable Mobility on sectoral implementation. Transport, for its part, leads infrastructure planning, services, and the Sustainable Mobility Law, so transport decarbonization is clearly a shared competence.

MITECO's competence basis in transport

The ministerial structure royal decrees (not reproduced here, but summarized in the function sheets) assign to MITECO's Secretary of State for Energy responsibility over energy policy, energy planning and strategy, economy decarbonization, and coordination with other departments in these matters, according to the Ministry's energy functions and competencies page (Secretary of State for Energy functions). This architecture enables MITECO to regulate fuels, set emission targets, and design economic instruments applicable to transport, although mobility system management falls to Transport.

In parallel, MITECO's specific mitigation and transport website states that the ministry acts on the sector by setting climate and energy targets and integrating transport into national climate policy (transport mitigation).

Normative and planning instruments managed by MITECO

MITECO leads the strategic decarbonization framework that conditions transport:

• National Integrated Energy and Climate Plan (PNIEC): the central piece of energy and climate planning. The Sustainable Mobility Law, analyzed by the newspaper Demócrata, establishes that the PNIEC must include concrete and quantifiable emission reduction targets for transport, linked to increased renewables and reduced GHG intensity (Sustainable Mobility Law impact analysis; T&E article). Other Demócrata articles highlight how the PNIEC promotes modal shift towards public transport and requires electrification of new bus acquisitions (ATUC and PNIEC).
• Long-Term Decarbonization Strategy 2050, whose draft positions the PNIEC as a medium-term tool on a coherent path towards climate neutrality (Decarbonization Strategy draft).
• Sectoral energy strategies (biogas, renewable hydrogen, etc.), which condition the fuel mix in transport (biogas document; renewable hydrogen roadmap).

Regulation of renewable fuels and electrification

Normatively, MITECO has promoted a royal decree project to transpose the new Renewable Energy Directive and set emission reduction and renewable penetration obligations for fuel suppliers in road, non-electrified rail, maritime cabotage, and coherently, aviation (MITECO note on renewable fuels RD; also summarized in Moncloa note and critically commented by the sector in APPA Biocarburantes article and increase of biofuel quota).

This royal decree introduces a methodology based on GHG reduction, sub-targets for advanced biofuels, biogas, and non-biological renewable fuels, and also an e-credits system for renewable electricity managed by MITECO to account for energy consumed by electric vehicles (MITECO note).

On electrification, MITECO designs and finances aid programs such as MOVES Corridors and MOVES Fleets Plus, which support charging infrastructure and electrification of business fleets, managed by IDAE (MITECO note on MOVES; IDAE note). It also expands catalogs of efficiency measures including electric vehicle technologies and collaborative mobility as core to mobility decarbonization (efficiency measures catalog).

Coordination with Transport and other departments

The sectoral part (network planning, services, operating conditions) falls to the Ministry of Transport and Sustainable Mobility, supported by the Safe, Sustainable, and Connected Mobility Strategy 2030 (note on Mobility System governance; commented in Demócrata analysis and opinion articles such as “The mobility we deserve…” and “The four pillars of the Sustainable Mobility Law”). The Sustainable Mobility Law strengthens cooperation between both ministries.

A clear example of this shared governance is the Social Plan for the Climate, submitted for public information jointly by MITECO, Transport, and Housing, with 4.376 million euros allocated to transport to facilitate access to clean alternatives and reduce transport poverty (MITECO note; Moncloa note; political coverage in Demócrata article).

Likewise, the Sustainable Mobility Law obliges charging providers to submit information to MITECO and assigns it a State Plan for the deployment of charging infrastructure, while Transport regulates the concession system, governance bodies (Territorial Forum and Superior Council of Sustainable Mobility), and sectoral decarbonization obligations of fleets, including specific bus decarbonization programs funded by both Transport and MITECO (gas stations and charging points; Senate negotiations; agreed amendments and coverage on the break with Junts).

Other relevant references

To complete political and regulatory context on transport decarbonization and sustainable mobility, among others, the following Demócrata and Government materials can be consulted: debate on nuclear amendments, T&E assessment, announcement of decarbonization aid, debate on Auto Plan 2030, Just Transition Strategy, T&E and the law, ministry profile, and the Spanish mobility strategy consultation on MITECO's website (Spanish mobility strategy).

Biofuel and other renewable fuel certificates in Spain can only be requested by operators who, in addition to being subjects of the obligation system in transport, prove compliance with stringent sustainability, traceability, and information submission requirements before the Ministry for the Ecological Transition and the Demographic Challenge, which acts as the certification entity. The key regulations are Royal Decree 1085/2015, promoting biofuels, Royal Decree 376/2022 on sustainability and guarantees of origin of renewable gases, Royal Decree 235/2018 on emissions information, and Order TED/728/2024, which develops the promotion mechanism and certification system (SICBIOS). Additionally, the Resolution of 14 May 2025 specifies the information that obligated parties must submit to obtain certificates for non-biological renewable fuels.

Basic regulatory framework

The certificate system is based, among others, on the following regulations:

• Royal Decree 1085/2015, of 4 December, promoting biofuels (text RD 1085/2015), which sets sales or consumption targets and the use of certificates as a control mechanism.
• Royal Decree 235/2018, of 27 April (RD 235/2018), which establishes calculation methods and information requirements on fuel emission intensity in transport.
• Royal Decree 376/2022, of 17 May (RD 376/2022), which regulates sustainability and emission reduction criteria for biofuels, bioliquids, and biomass fuels, and the guarantee of origin system for renewable gases.
• Order TED/728/2024, of 15 July (Order TED/728/2024), which develops the promotion mechanism and certification system for biofuels and other renewable fuels for transport purposes.
• Resolution of 14 May 2025, of the Secretary of State for Energy (Resolution 14-5-2025), which specifies the information to be submitted for the accounting of non-biological renewable fuels.

Relevant antecedents also include Order ITC/2877/2008, partially repealed (Order ITC/2877/2008), the former Royal Decree 1597/2011, partly repealed (RD 1597/2011), CNMC Circular 5/2020 (Circular 5/2020), Circular 2/2017 (Circular 2/2017), and previous Circulars such as 1/2013 (Circular 1/2013).

Who can request certificates

Obligated parties are defined in Article 3 of Royal Decree 1085/2015 and Article 4 of Order TED/728/2024: essentially, operators who sell or consume gasoline, diesel, and other fuels for transport purposes in Spain. Only these obligated parties can request, before the certification entity (the Ministry), the issuance of biofuel and other renewable fuel certificates through the SICBIOS system provided in Order TED/728/2024.

Sustainability, traceability, and verification requirements

For fuels to generate computable certificates, operators must comply with the requirements of Title I of Royal Decree 376/2022:

• Sustainability and emission reduction criteria: biofuels, bioliquids, biomass fuels, and biogas for transport must meet greenhouse gas emission reduction thresholds and respect land use criteria.
• Verification report: economic agents must have a report issued by a verification entity (Art. 11 of RD 376/2022) certifying:
  • Application of a mass balance system ensuring product traceability.
  • Correct calculation of emission reductions and accreditation of raw materials used.
• Auditable system and document retention: all chain agents must maintain an auditable system and keep evidence for at least five years, subject to inspections by the Ministry and, if applicable, the European Commission.

If these requirements are not met, biofuels and renewable fuels cannot be counted for targets nor generate valid certificates.

Information obligations and minimum documentation

Generally, obligated parties must submit to the Directorate General for Energy Policy and Mines and the certification system the information necessary to:

• Identify batches of biofuels and other renewable fuels sold or consumed.
• Prove their origin, raw material type, production process, and sustainability characteristics.
• Allow tracking in the European database provided in Article 28 of Directive (EU) 2018/2001, as required by RD 376/2022.

For non-biological renewable fuels, the Resolution of 14 May 2025 specifies that the amount for which certificates (type E in SICBIOS) can be requested is the sum of sales or consumption in Spain that:

• Have associated renewable gas guarantees of origin redeemed with final use in transport (according to Order TED/1026/2022, which Order TED/728/2024 modifies).
• Prove compliance with Article 27.6 of Directive (EU) 2018/2001 on accounting as renewable of electricity used.
• Achieve a GHG emission reduction of at least 70% compared to the reference fossil fuel (94 g CO₂eq/MJ).

This information can be entered into SICBIOS from 15 May 2025, when the system is enabled for type E certificates, according to Article 12 of Order TED/728/2024.

Limits, denial, and effects on certificates

Order TED/728/2024, in connection with Article 2 of RD 1085/2015 and Article 3 ter thereof, sets limits on:

• The percentage of biofuels from food and feed crops.
• Fuels with high risk of indirect land use change (ILUC).
• Biofuels from certain raw materials (Part B of Annex I of RD 376/2022), which can only be partially counted.

For compliance with targets, the Order establishes that certificates exceeding these limits will not be considered, neither for obligation accounting nor for the distribution of compensatory payment accounts. In practice, this equates to denial or ineffectiveness of certificates issued on volumes that do not respect these caps or do not prove sustainability.

Other related regulatory references

As general context for the energy and biofuels sector, the regulations cite other provisions, including Law 11/2013 (Law 11/2013), Royal Decree-Law 6/2000 (RDL 6/2000), Law 8/2015 (Law 8/2015), Royal Decree-Law 28/2018 (RDL 28/2018), and Law 31/2015 (Law 31/2015), as well as targets set by previous biofuels royal decrees such as RD 459/2011 (RD 459/2011), although the specific requirements for certificate requests are mainly found today in RD 376/2022, RD 1085/2015, RD 235/2018, and Order TED/728/2024.